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Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

Banking and financial services

In the Action Plan on Sustainable Finance the Commission expressed intention to clarify fiduciary duties and increase transparency in the field of sustainability risks and sustainable investment opportunities with the aim to -reorient capital flows towards sustainable investment; -assess and manage relevant financial risks stemming from climate change, resource depletion, environmental degradation and social issues; and -foster transparency and long-termism in financial and economic activity.

Links

Public consultation

ID: 12068

Lobbying Activity

36 responses

Consultation response

WWF European Policy Programme, 6 Jul 2020

The European Commission has added in all the considered Articles ‘including any sustainability preferences’ (especially for the product governance obligations – Delegated Directive (EU) 2017/593) or ‘including his or her sustainability preferences/factors’ (in the Delegated Directive (EU) 2017/565…

Consultation response

Fédération bancaire française, 6 Jul 2020

The FBF welcomes the EC consultation on the amendments to the MiFID II Delegated Regulation (EU) 2017/565 and Delegated Directive (EU) 2017/593 as regards the integration of sustainability factors, risks and preferences. I. MiFID ESG consultations 1. Implementation timeline • Investment firms will…

Finance industry urges nine-month delay for ESG suitability rules

Association for Financial Markets in Europe, 6 Jul 2020

The Associations request a nine-month implementation delay after product governance rules take effect. They argue firms need time to update client profiles and source ESG data, citing significant data availability issues. They also seek clarity that ESG assessments should only apply to products with sustainable objectives.
This would give them more time to upgrade IT systems and avoid clashing with other 2021 regulatory deadlines.
Investors seeking ESG products face continued uncertainty about which investments meet sustainability preferences.

Banking Federation Seeks Delay for ESG Investment Rules

European Banking Federation, 6 Jul 2020

The federation requests extended implementation deadlines and clarification of regulatory definitions. They argue sustainability preferences should reference only Articles 8 and 9 of existing regulations without additional criteria. They want explicit confirmation that existing contracts don't require reassessment.
This would reduce implementation costs and give banks more time to update IT systems.
Investors seeking sustainable options lose immediate access to clear ESG product information.

Consultation response

Finanssiala ry - Finance Finland, 6 Jul 2020

Finance Finland's (FFI) response to the Commission’s draft amendments on the integration of sustainability considerations into MiFID II • The definition of ESG-compliant products should not be narrowed under MiFID. The definition of sustainability preferences should refer to the existing…

Consultation response

Invest Europe, 6 Jul 2020

As a starting point, we would like to note that private equity fund managers are typically regulated under the Alternative Investment Fund Managers Directive (AIFMD). However, some private equity businesses or sub-businesses might also operate under a MiFID licence. Private equity firms holding a…

Consultation response

Associazione Bancaria Italiana, 6 Jul 2020

This document constitutes ABI's contribution to the consultation launched by the European Commission on the amendments to the MiFID II Delegated Regulation (EU) 2017/565 and the Delegated Directive (EU) 2017/593 regarding the integration of sustainability factors, risks and preferences into certain…

Consultation response

Asociación Española de Banca, 6 Jul 2020

The Spanish Banking Association welcomes the opportunity to respond to the draft amendments of the MiFID Delegated Regulation. Please find enclosed our full response.

ICI Global urges EU to include broader sustainable products

Investment Company Institute, 6 Jul 2020

ICI Global requests revising the definition of 'sustainability preferences' to include both Article 8 and Article 9 products. They argue the current proposal effectively eliminates a key category of sustainable investments.
This would maintain the market for diverse ESG products and prevent high compliance costs.
Retail investors lose access to diverse strategies, and smaller firms face high barriers.

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 30 Jun 2020

BVI is fully supportive of creating an enabling framework for sustainable investments that will facilitate the transition to a more sustainable European economy. However, in order to create an enabling regulatory environment, we request the Commission to fully align the understanding of…

Consultation response

European Association of Co-operative Banks, 6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4);…

Consultation response

Association Française de la Gestion financière, 6 Jul 2020

Please find in the document attached more detailed feedback from the French Asset Management Association (AFG) on these proposals The proposed approach to the definition of sustainability preferences in Article 1 of the Delegated Act seems overly restrictive: - It ‘goldplates’ level 1 and…

Consultation response

Fairshare Educational Foundation (ShareAction), 6 Jul 2020

ShareAction welcomes the proposals to amend delegated regulations under MiFID II to ensure a better integration of sustainability preferences and risk into organisational requirements and operating conditions for investment firms. However, we believe more granular requirements are needed on the…

Consultation response

European Fund and Asset Management Association, 6 Jul 2020

EFAMA has always been a firm supporter of creating a strong framework for sustainable investing which facilitates the transition to a more sustainable European economy. In this context, we see the Commission’s work on integrating sustainability considerations into MiFID II as an essential…

European retail banks urge harmonized sustainability rules for advice

European Savings and Retail Banking Group, 7 Jul 2020

Exclude derivatives from the scope as they are primarily used for hedging business risks. Requirements for sustainable products must be harmonized to ensure a strategy product is not treated as unsustainable. Banking rules should treat sustainability as a risk driver rather than a separate risk type.
Avoiding separate risk categories reduces administrative complexity and lowers overall compliance costs.
Clients would be unable to align their derivative-based hedging strategies with sustainability preferences.

Consultation response

European Federation of Investors and Financial Services Users, 6 Jul 2020

BETTER FINANCE welcomes the introduction of requirements for firms providing investment advice and portfolio management to ask clients about their non non-financial objectives and preferences. This is an important step forward for the integration of sustainability in the fiduciary duties of…

Consultation response

European Association of Public Banks and Funding agencies AISBL, 6 Jul 2020

Misalignment between MiFID II Delegated Acts and SFDR when defining sustainability preferences The new provisions of Article 2(7)(b) MiFID II Delegated Regulation and Article 1(5) second bullet point MiFID II Delegated Directive extend the definition of “sustainability preferences” by referring to…

Consultation response

Nederlandse Vereniging van Banken / Dutch Banking Association, 2 Jul 2020

The NVB would like to respond to the proposed amendments regarding Suitability and Product Governance, consolidated in one reaction. Please find our response attached.

Consultation response

The Alternative Investment Management Association Limited, 6 Jul 2020

AIMA and MFA have been actively engaging on the topic of sustainable finance with the European Commission and European policy-makers to contribute to the development of an effective and impactful sustainable finance environment. Our engagement seeks to ensure that investors and market players have…

Consultation response

Aviva Plc, 6 Jul 2020

Aviva welcomes the publication of this suite of draft Delegated Acts, which implement important parts of the Sustainable Finance Action plan. We strongly support the policy intent to incorporate sustainability into suitability assessments, fiduciary duties and organisational requirements.…

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 6 Jul 2020

The Association of the Luxembourg Fund Industry (ALFI) represents the face and voice of the Luxembourg asset management and investment fund community. Created in 1988, the Association today represents over 1,500 Luxembourg domiciled investment funds, asset management companies and a wide range of…

Consultation response

The Investment Association, 6 Jul 2020

Overarching Comment: As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the…

Consultation response

Principles for Responsible Investment, 6 Jul 2020

The proposed amendments to the delegated acts underpinning MiFID state that sustainability risks should be considered in risk management, conflict of interest and governance, but do not directly address the need to integrate sustainability risks when determining how to act in the best interests of…

Schroders urges alignment of sustainability definitions with SFDR rules

Schroders Investment Management (Europe) SA, 6 Jul 2020

Schroders wants to remove extra restrictions on sustainable products to match previous legislative agreements. They also propose conducting client sustainability assessments during regular annual reviews.
This would lower compliance burdens for smaller firms by avoiding unnecessary mandatory reporting requirements.
Retail investors lose access to a wider range of products due to restrictive definitions.

Consultation response

Invesco Management SA, 6 Jul 2020

The overarching objectives set out in the European Commission’s Sustainable Finance Action Plan is to re-orient capital flows towards a more sustainable economy and to mainstream sustainability. The ambition being to incentivise financial market participants to offer sustainable investing options…

Consultation response

Związek Banków Polskich, 6 Jul 2020

Please find enclosed the opinion of the Polish Bank Association on sustainable finance - obligation for investment firms to advise clients on social and environmental aspects of financial products.

Consultation response

Swedish Securities Markets Association (Swedish: Föreningen Svensk Värdepappersmarknad), 6 Jul 2020

Feedback from SSMA, see attachment.

Consultation response

Die Deutsche Kreditwirtschaft, 6 Jul 2020

1. Derivatives should be excluded from the scope of application. These products often serve to hedge business risks where sustainability considerations play no role. 2. The proposed widening of the new definition of sustainability preferences in Art. 2 (7) (b) MiFID II draft Delegated Regulation…

Consultation response

Irish Funds Industry Association CLG, 6 Jul 2020

We broadly welcome the draft Delegated Act on integrating sustainability factors and preferences into the product governance obligations for MiFID firms and the integration of sustainability factors, risks and preferences in the organisational requirements for MiFID firms. We note that the revised…

Consultation response

Association Française des Marchés Financiers, 6 Jul 2020

AMAFI welcomes the opportunity to give feedbacks on European Commission proposed amendments to delegated acts under MiFID II to include sustainability factors into the advice that investment firms offer to individual clients. Indeed, AMAFI pays particular attention to the development of ESG…

Consultation response

Novamont SpA, 3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of…

Consultation response

Bundesverband für strukturierte Wertpapiere, 6 Jul 2020

The DDV welcomes the opportunity to provide comment on the present consultation on integrating sustainability factors and preferences into the product governance obligations in MiFID II. The DDV recognises that aligning the real economy with sustainability is one of the most important and demanding…

Consultation response

Genossenschaftsverband Bayern, 25 Jun 2020

Siehe angehängte Datei

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 6 Jul 2020

DECO – the Portuguese Consumer protection Association, welcomes and supports the amendments proposed. These measures are necessary in order to foster the implementation of the Green Deal, the promotion of sustainability, and in particular sustainable finance. It is crucial to have mandatory…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 6 Jul 2020

BIPAR welcomes the opportunity provided by the European Commission to comment on its proposed Delegated Regulation amending the Delegated Regulation (EU) 2017/565 as regards the integration of sustainability factors, risks and preferences into certain organisational requirements and operating…

Consultation response

Dutch Fund and Asset Management Association, 6 Jul 2020

See attached file